Transition tax penalty relief, Section 965 update

In a new press release on June 4, 2018, the IRS announced its decision to provide penalty relief to certain taxpayers who were delinquent in making a tax payment for the new transition tax. Section 965 of the code, also known as the transition tax, is a one-time tax on the accumulated earnings held in …

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What’s new with 2017 Form 1042-S

Another year means more updates to Form 1042-S as the IRS attempts to have these forms work more efficiently and adapt to the ever changing tax laws. Here is what’s new for 2017: Unique form identifier: Each 1042-S form will now need to have a unique form identifier. This is different than a U.S. or …

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Foreign earned income exclusion & retirement savings

Do you think your accountant asks you too many questions? Do you feel interrogated? I’d just like to remind you that we are on your side and we aren’t the ones issuing penalties. We are here to help prevent those penalties, but we can only use the information that is given to us (shocking, I …

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Updated regulations on IRC Sections 987 and 988

On December 7, 2016, the IRS released temporary regulations under IRC Sections 987 and 988, which provide guidance on recognizing foreign income or loss as well as currency gain or loss from a qualified business unit (QBU). The original proposed regulations (regs) were issued back in 1991. In 2006, the 1991 proposed regs were replaced …

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New Form 5472 requirements for foreign-owned disregarded entities

Under the proposed Internal Revenue Code Section 6038A regulations issued on May 6, 2016, U.S. disregarded entities owned by foreign persons would be treated as domestic corporations for purposes of filing Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business. The new regulations …

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